United States v. McQuarry, No. 14-3605 (8th Cir. 2016)
Annotate this CaseDefendant appealed her conviction for one count of conspiracy to defraud the United States and two counts of making a false claim against the United States. Defendant's convictions stemmed from her filing of fraudulent 1099-OID forms. Defendant argued that the district court erred when it excluded a video about fractional-reserve banking from evidence that she claims supported her good-faith defense. The court concluded that the district court's exclusion of the video from the jury deliberations did not affect defendant's substantial rights and admission of the video would not have changed the verdict. Accordingly, the court concluded that the district court did not err in excluding the video. The court affirmed the judgment.
Court Description: Riley, Author, with Smith and Shepherd, Circuit Judges] Criminal case - Criminal law. In this prosecution for conspiracy to defraud the U.S. and making a false statement by filing fraudulent 1099-OID forms, the district court did not err in refusing to permit defendant to introduce a video explaining a minimally-related complex banking scheme as exclusion of the video did not affect defendant's substantial rights and admission of the video would not have changed the verdict.
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